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Debate over the reality of meeting the 54.5 mpg by 2025 goal has been flared between environmentalists, regulators, and automakers as the U.S. Midterm Evaluation ensues.

The inflated sales of pickup trucks, SUVs, and crossovers coming from cheap gas prices has changed the outlook for the 2025 target closer to “51 mpg” – realistically, somewhere in the mid-upper 30s on window stickers. The 1,217-page draft “Technical Assessment Report” was issued on July 15 by the Environmental Protection Agency, National Highway Traffic Safety Administration, and California Air Resources Board for a 60-day public comment period.

The 54.5 mpg target originally was a projection based on the assumption that 67 percent of production in 2025 would consist of cars, and 33 percent would be light trucks. Low fuel prices have kept demand for pickups, SUVs and crossovers at around 50 percent of the market, prompting regulators to update their outlook. The mpg equivalent includes projected corporate average fuel economy and additional points through reductions in tailpipe carbon dioxide emissions and credits that automakers can use to meet the standards.

Hitting the 54.5 mpg mark has never been a mandate being enforced by the agencies, which was acknowledged in the midterm report. The standards were enacted to support federal and state emissions goals, and provide a series of curves that dictate, for each size and type of vehicle, an individual fuel economy target. It was designed to encourage automakers to build more fuel-efficient models and add more plug-in electrified vehicles to their product lineups.

Government agencies hailed the findings of the report as evidence that the industry is ahead of schedule in complying with the Obama administration’s ambitious National Program of harmonized greenhouse gas and fuel economy regulations. EPA, NHTSA, and CARB say the industry has ample technology available to achieve the challenging targets without relying too heavily on hybrids and PEVs. They also warned that keeping the current 2025 standards in place will miss the mark on the 54.5 mpg goal, as consumers are buying too many light trucks.

Stephanie Brinley, a senior analyst with IHS Automotive, said the midterm evaluation is a “transparent system and process” that is “more collaborative” than past auto regulatory pushes. But that doesn’t mean there won’t be friction, she said.

Industry trade group Alliance of Automobile Manufacturers agreed that understanding the midterm review analysis right is crucial for everyone involved. But the 2022-2025 federal fuel economy goals will make it difficult for automakers, the alliance said

“It will be a daunting challenge to meet the very aggressive requirements of the 2022-2025 federal fuel economy regulations and greenhouse gas rule,” the alliance said in a statement.

One key point to work out likely will be the extent to which automakers must develop and sell PEVs to meet the 2025 standards. The EPA expects PEVs to account for less than 3 percent of the 2025 U.S. fleet, factoring in sales required by California’s Zero Emission Vehicle mandate.

The midterm report did acknowledge the impact advanced vehicle technologies are having on improving fuel economy. About 45 percent of 2015 model year vehicles had gasoline direct injection, up from just 2 percent in the 2008 model year, according to the report.

As for automakers, how they achieve the federal guidelines will be vary by their product lineups and technology choices. Robert Bienenfeld, assistant vice president for U.S. environmental strategy at Honda, says automakers will scrutinize whether the report’s findings on technologies such as stop-start, 48-volt mild hybrids and many others line up with their own.

“As the regulations become more and more stringent, there are fewer technologies that can help us achieve those more ambitious goals,” Bienenfeld said, “and more electrification will be required as we move into the future.”

Environmental groups argue that the report shows the original goals are firmly within the industry’s grasp.

“Continuing to strengthen clean vehicle standards is good for America’s consumers – and it’s absolutely critical to bringing about cleaner, healthier air and a more stable climate,” said Luke Tonachel, director of the Clean Vehicles and Fuels Project at the Natural Resources Defense Council.

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